Roundup: Probably Carcinogenic, and What Else?

It’s now widely known that Roundup has been found to be a probable carcinogen by the World Health Organization. (We wrote about that here: WHO – Roundup Probably Carcinogenic).

This is particularly disturbing, because it’s a very widely-used pesticide and the amounts found in humans have increased 5x since 1994 according to a UCSD study. Not only is it used in agriculture, it’s (still) used in our parks. Marin County has prohibited its use on public properties, but San Francisco’s Department of the Environment only reclassified it from Tier II (More Hazardous) to Tier I (Most Hazardous). The Natural Resources Department (NRD) of San Francisco Recreation and Parks Dept (SFRPD) continues to use it.

Photo of warning sign. Garlon, Aquamaster, Milestone on Mt Davidson. March 2018

Garlon, Aquamaster, Milestone on Mt Davidson. March 2018

But it’s not just a probable carcinogen. Research indicates a bunch of other issues:

VERY LIKELY AN ENDOCRINE DISRUPTOR

It’s very likely to also be an endocrine disrupter, which means it acts like a hormone in the human body, and can be a problem at very low doses.

Hormone disruption diagram - Source: NIH

Hormone disruption – Source: NIH

In a letter an EPA scientist Dr Marion Copley sent before she died, she not only said it was carcinogenic, she noted “glyphosate was originally designed as a chelating agent…” and lists the issues with chelating agents, including, “Chelaters are endocrine disrupters…” (That article is here: “It is essentially certain that glyphosate causes cancer.”)

If you want to read about how endocrine disruptors work, that’s a link to the National Institutes of Health website. It notes: “Research shows that endocrine disruptors may pose the greatest risk during prenatal and early postnatal development when organ and neural systems are forming.”

BIRTH DEFECTS IN VERTEBRATES

A paper published May 2010 in the journal, Chemical Research in Toxicology linked glyphosate to birth defects in vertebrates. We’d like people who have assumed that Roundup’s problems come mainly from its surfactant POEA to take a look. (This is not to say POEA is harmless. That has been implicated in embryonic cell death also, in a 2008 French study published in the same journal.)

In Argentina, glyphosate (the active ingredient of Roundup) is widely used on soybean. In soybean-growing areas, there were reports of increased birth defects of a particular type: malformed heads, eyes, and brains. A groups of researchers therefore decided to investigate whether glyphosate could indeed cause that type of birth defect.

The abstract of the article indicates that Roundup increased retinoic acid activity in vertebrate embryos, causing “neural defects and craniofacial malformations.”

Heart-breaking Birth Defects

Women of child-bearing age should be especially careful. The most vulnerable period, according to the paper, is in the first 2-8 weeks of pregnancy. Many people don’t even know they’re pregnant that early on. Furthermore, even the mature placenta is permeable to glyphosate. After 2.5 hours of perfusion, 15% of it crosses over.

The actual article, which we read elsewhere describes some of the birth defects: microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead, like the picture here); and neural tube defects. These are quite devastating. Many fetuses do not come to term, and many babies with these conditions die within hours or days.

INTERFERING WITH REPRODUCTION

There’s some evidence that glyphosate interferes with male reproduction, too. A 2014 article published in Science in Society in the UK, entitled “Glyphosate/ Roundup and Human Male Infertility” links glyphosate to falling sperm counts and lowered testosterone levels.

National Institutes of Health published a  paper in August 2000 that indicated Roundup interfered with reproductive hormones in rats.

DISRUPTION OF GUT BACTERIA

Other research has implicated glyphosate in other risk factors, particularly since it can disrupt gut bacteria in humans. We wrote about that here: Pesticides and Cancer, Glyphosate and Gut Bugs.

A 2013 article at RodalesOrganicLife.com suggests the growing evidence against glyphosate, possibly the world’s most widely used herbicide: ‘Once called “safer than aspirin,” glyphosate’s reputation for safety isn’t holding up to the scrutiny of independent research. More and more non-industry-funded scientists are finding links between the chemical and all sorts of problems, including cell death, birth defects, miscarriage, low sperm counts, DNA damage, and more recently, destruction of gut bacteria.’

Researchers found that glyphosate residues on food interfere with certain enzymes, with the result that  “…glyphosate enhances the damaging effects of other food borne chemical residues and environmental toxins. Negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems throughout the body.”

[That paper, published in 2013 the journal Entropy, is HERE.]
It suggests that glyphosate might be causing a lot of the health problems that have been associated with Western diets – including “obesity, diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease.”

BAD FOR THE ENVIRONMENT AND MOST LIVING THINGS

Glyphosate is bad for most living things. Research by way of a review of literature published in December 2017 by Springer Publishing concluded:

“Glyphosate poses serious threat to multicellular organisms as well. Its toxicological effects have been traced from lower invertebrates to higher vertebrates. Effects have been observed in annelids (earthworms), arthropods (crustaceans and insects), mollusks, echinoderms, fish, reptiles, amphibians and birds.”

It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

It damages the soil. How? It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil. Research also indicates it kills beneficial soil fungi while allowing dangerous ones to grow.  There’s a good article about that on the Million Trees website: Gyphosate (AKA Roundup) is damaging the soil  that discusses a New York Times article on the subject.

WHO’S USING GLYPHOSATE?

Most of SFRPD has continued to decrease use of glyphosate in 2017 – except for the Natural Resource Department (NRD, formerly Natural Areas Program – NAP). Here’s the comparison.

These graphs are in fluid ounces of active ingredient. The blue section is the use in 2016, and the orange section shows 2017.  NRD actually used slightly less glyphosate in 2016 than the rest of SFRPD (excluding Harding Golf Course, which is managed under an outside PGA contract). But in 2017, it used nearly 2 1/2 times as much.

Bear in mind that NRD accounts for a quarter of our park land in San Francisco.

Though we are glad SFRPD has been reducing use, we should be wary: Why Low Dose Pesticides are Still HazardsEndocrine disruptors can act at very low dilutions, and in their case, the old adage that the “dose makes the poison” is not true.

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San Francisco “Natural Resources” Herbicide Usage Up 57% in 2017

We have recently analyzed the data for herbicide use in the full year 2017 for San Francisco’s so-called “Natural Resources Department” (NRD – formerly Natural Areas Program). It’s up 57% from the previous year.

NRD is a department of San Francisco Recreation and Parks Department (SFRPD). We were greatly encouraged when NRD started reducing herbicide use in 2014. Before that, pesticide use had increased sharply from 2009 onwards. (You can read an article about that here: SF’s Natural Areas Program – more pesticide in 2013.) Another sharp reduction in 2016 was even more encouraging – though it’s never come down to 2008 or 2009 levels. (The graph above shows annual NRD herbicide usage in fluid ounces of active ingredient.)

But this year, it’s up again, almost to 2015 levels. We have been hoping that SFRPD is working to eliminate all Tier I and Tier II herbicides, with leadership from the Department of the Environment (SF Environment).

For the rest of SFRPD (excluding Harding Golf Course, which is managed under a PGA contract), they have actually reduced usage. They use a greater variety of herbicides than NRD, of which more later. But they are using less – across all their parks and golf courses – than the NRD is. NRD forms a quarter of the area of SFRPD.

WHAT’S WRONG WITH THESE HERBICIDES?

NRD uses four herbicides: Two that SF Environment classifies as Tier I (“Most Hazardous”) and two classified as Tier II (“More Hazardous”). The Tier I herbicides are Roundup/ Aquamaster (glyphosate) and Garlon 4 Ultra (triclopyr); and Stalker/ Polaris/ Habitat (imazapyr) and Milestone VM (Aminopyralid) are Tier II. (In the first picture, with the white dog, the sign posted on Mount Davidson indicates they are using Aquamaster, Garlon, and Milestone in March 2018.)

These hazard rankings can change: Roundup/ Aquamaster (glyphosate) was reclassified from Tier II to Tier I when the World Health Organization found it was a probable human carcinogen. Milestone (Aminopyralid) was reclassified from Tier I to Tier II, despite the fact that it is extremely persistent and mobile in the environment.

THE FEARSOME FOUR

As you research these herbicides, you may find – as we did – that much of the research originates with the companies that produce them. It may be unbiased, but the evidence is that it often is not. So we looked for other sources, which are easier to find for well-established herbicides like glyphosate (Roundup or Aquamaster). It doesn’t mean the others are innocuous.

ROUNDUP or AQUAMASTER (Glyphosate)

  • Carcinogenic. In April 2015, the World Health Organization determined glyphosate was a “probably carcinogenic.”  EPA scientist Dr Marion Copley  sent a letter before her death saying it was essentially certain that glyphosate  causes cancer. She also said that as a chelater, it was likely an endocrine disruptor.
  • Associated with birth defects. It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).
  • Bad for the soil. Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
    It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • Bad for other living things. It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

  • Garlon is even more hazardous than Roundup. It’s been classified as Tier I for at least as as long as we have been monitoring pesticide use in San Francisco.
  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  • Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  • About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs  may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans.  Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  • It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  • It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Garlon can persist for up to two years in dead vegetation .

The NRD uses Garlon extensively against oxalis. If it terminated its war on oxalis, it could stop using Garlon altogether.

POLARIS, HABITAT, STALKER  (Imazapyr)
This is a relatively new pesticide, and not much is known about it — except that it’s very persistent. In Sweden, it was found in the soil 8 years after a single application. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment.

It can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product  is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”
It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001 because of groundwater concerns.

MILESTONE (Aminopyralid)
Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as  a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.
Nevertheless, after an outcry and problems, Dow AgroSciences stopped selling Milestone in the UK for a number of years. It’s also prohibited for use in New York.

IT’S TIME TO STOP

There’s growing evidence that herbicides are more dangerous, more mobile, and more persistent than their manufacturers claim. Glyphosate, for instance, is widely found in all water sources, in the soil – and in people. A UCSF study of glyphosate in urine found: “Glyphosate residues were observed in 93% of urine samples in voluntary public testing in the U.S. general population; this is higher than the frequency observed in Europe using GC-MS (43.9%)”  and “exposure is likely due to dietary intake or environmental exposure.”

With endocrine disruptors, the old theory “the dose makes the poison” doesn’t work. They are potent at very low levels.

These are parks that we visit with our families, including kids and pets. Kids are particularly vulnerable to pesticides because of their low body weight and rapid growth. These are the watersheds that feed chemicals into our groundwater (which is also now being added to our domestic water supply).

The San Francisco Forest Alliance stands for No Pesticides in our Parks.

Important Pesticide Meeting at City Hall, 20 Dec 2017

Toward the end of each year, SF Department of the Environment (SF Environment), which runs the Integrated Pest Management Program (IPM) holds an important public meeting. This year, it’s on December 20, 5-7 p.m. in Room 400 at San Francisco’s City Hall.

This meeting is to discuss three things, and take public comments and input: Changes to the approved list of pesticides for city use; the guidelines for pesticides use and public notification; and explaining the exemptions granted in 2017 to the rules.

Notice showing Pesticides to be used on blackberry on Mt Davidson, San Francisco - Nov 2017

Pesticides used on blackberry on Mt Davidson – Nov 2017

THREE THINGS ON THE PESTICIDE MEETING AGENDA

1. Changes to the approved list of pesticides for use on city properties. SF Environment publishes a list of pesticides that are okay to use on city-owned properties (our parks, lands owned by the Public Utilities Commission, Crystal Springs, the airport, Sharp Park and a few others). It divides these permitted pesticides into three tiers: Tier III (Least Hazardous), Tier II (More Hazardous) and Tier I (Most Hazardous). This meeting discusses pesticides added, removed, or having their Tier classification changed.

The DRAFT for 2018 is here: b_draft_2018_reduced_risk_pesticide_list

2. Guidelines for pesticide use and public notification. Over the last year, IPM has been trying to develop guidelines for when and where these pesticides are prohibited; and also for how the public can be informed when pesticides are used. Here’s the current DRAFT of the guidelines: c_summary_of_major_changes_to_2017_restrictions_of_most-hazardous_herbicides

3. They also explain the exceptions they’ve granted in the previous year, i.e. 2017. They approved 21 exemptions in 2017. The list of exemptions is here: a_summary_of_pesticide_exemptions_for_2017

The one that particularly concerns us is permission to use Garlon 4 Ultra (probably the most toxic herbicide still permitted on City properties) on oxalis within fifteen feet of designated trails at Twin Peaks, Mount Davidson, McLaren Park, Bayview Hill and Corona Heights.

They argue: These parks have a diversity of native plants growing adjacent to trails including but not limited to: Grindelia hirsutula (gumplant), coast rock cress (Arabis blepharophylla), Pacific reed grass (Calamagrostis nutkaensis), stonecrop (Sedum spathulifolium), meadow white (Cerastium arvense), silver bush lupine (Lupinus albifrons), Mission bells (Fritilaria affinis), footsteps of spring (Sanicula arctopides), California buckwheat (Erigonium latifolium), soap plant (Chlorogalum pomeridianum), dichondra (Dichondra donelliana), varied lupine (Lupinus variicolor), California buttercup (Ranunculus californicus), checkerbloom (Sidalcea malvaeflora), campion flower (Silene scouleri) and coast red onion (Allium dichlamydeum). Many of these plants are considered sensitive species and some of them support important local wildlife, such as the lupine species that are host plants for the endangered Mission blue butterfly (Icaricia icariodes missionensis). SFRPD is obligated to manage the land at Twin Peaks for the Mission blue butterfly as part of the Recovery Plan with the U. S. Fish and Wildlife Service, including the management of oxalis. In recent years, Garlon 4 Ultra is being used to protect these sensitive areas from this invasive weed. The Oxalis pes-caprae is a major threat to the existing biodiversity of wildlife within the native grasslands. If left untreated these areas will greatly interfere with the progress already made in controlling this particular weed.

What it boils down to is the poorly-supported theory that oxalis will take over the world if they let it, an argument Nativist doyen Jake Sigg recently made in his newsletter while defending pesticide use. “Our most serious destroyer of biological diversity is the yellow oxalis, Oxalis pes-caprae. Because it is prolific, aggressive, and effectively practices chemical warfare, it is pushing out native species—the wildflowers that so delight us and which are needed as the base of the food chain for other creatures. Because it can’t be destroyed unless the bulb is killed, herbicides are mandatory.”

By contrast, actual research indicates oxalis is a poor competitor, and even the California Native Plant Society California Invasive Plant Council considers it only moderately invasive (mainly in sand dunes). [Edited to correct the organization reference.]

We understand that some opinions are influential even when opposing evidence surfaces, but in this case the tradeoff is the continued use of the most toxic herbicide that the city allows on its land. We’ve argued before that this tradeoff is not good for people, wildlife, or the environment. (See our presentation-format post: Garlon v. Oxalis in 10 Easy Slides ) We certainly do not wish it to be used near any trail where people go out with their kids and pets.

WE STAND FOR NO TOXIC PESTICIDES IN OUR PARKS

San Francisco Forest Alliance stands for an end to toxic pesticides in our parks. This can be done; the Marin Municipal Water District stopped using herbicides altogether some years ago. It means having a more practical approach to managing the landscape, and not declaring war on various species of plant.

However, we do have some concerns. Here are notes from Tom Borden, a public access advocate:

2017 exemptions
There is only one exemption from the posting requirements. It is for PUC right of ways. I understood pesticides were used at the GGP plant nursery without posting. Where is the exemption? I suspect herbicides are applied above the reservoir at 7th and Clarendon without posting. Where is the exemption for that?

Restrictions on Herbicides for City Properties
A2  Why are applications done by methods other than spray exempted from the requirement to use blue dye? If a stump has been daubed rather than sprayed, how will people know it’s not safe to sit on?

A2  Why say, “or in cases where posting is not otherwise required under the law”? Posting is always required by law, unless an exemption from posting is granted by IPM. Right now there is only one posting exemption on the IPM Exemptions log. If and when IPM issues another posting exemption, the land manager can also request an exemption from the blue marker dye requirement if there is a good reason to avoid the dye. Who does not want to use blue dye? Is it really expensive? Isn’t it beneficial to the people applying herbicides to be able to see what they already treated? Why shouldn’t people be able to see what was treated?

A7  Why can’t herbicides be used on green walls and green roofs? Whatever that logic is, why doesn’t it apply more broadly?

B9  Why don’t the protections for the public and employees extend to areas outside city limits? Do we only care about people in San Francisco?

B9  What is the relevance of public accessibility? The Chapter 3 of the San Francisco environment code protects City employees as well as the public. If “publicly inaccessible parcels” are to have lesser requirements for posting and demarcation, the law requires that the land manager apply for an exemption. As of today, there is only one posting exemption on file, for PUC rights of way. There should also be one for the GGP nursery. Other than that, we are not aware of any other “publicly inaccessible parcels” in the City. The general exception for “publicly inaccessible parcels” should be removed. It just introduces unnecessary ambiguity. If there is a genuinely publicly inaccessible parcel, and City employees can be protected, then IPM can issue an exception for that.

B9  Why are golf courses and areas managed for habitat conservation afforded less public protection? Don’t golfers, kids and hikers deserve protection too? Maybe the behavior of golfers is predictable, but people enjoying our wild parkland could be having a picnic, playing hide and seek, exploring, rolling down a hill, doing almost anything. There should be no exception to the demarcation requirements for “areas managed for habitat conservation”.

B12  If a trail exists, especially one not “actively maintained by City operations”, it is because people use it frequently. If the intent of these rules is to protect the public, all trails should be afforded the same protection. If the intent of these rules is to make life easy for land managers and punish people who use un-designated trails, you are on the right track.

B13  Please remove spray boom “definition” for broadcast spraying. The last part of the second sentence gets to the point, broadcast spraying means indiscriminately spraying all plants in an area, as opposed to targeting specific plants. In 2016 you saw video and photographic evidence that three men with backpack sprayers can perform broadcast spraying. Please use the definition for broadcast spraying that the rest of the world uses.

New thinking on Tier I
The new Restrictions do away with the idea that Tier I herbicides are only to be used when there is a critical need. Now Tier I can be used for anything except for prohibitions 10,11 & 12. The old restrictions limited where Tier I herbicides could be used based on a “need” that was balanced against the risks of use. Where has that gone? This seems like a real step backward.

Now land managers just need a reason that goes beyond cosmetics and they can apply Tier I herbicides anywhere as long as it is more than 15 feet from an area frequented by children and more than 15 feet from the land manager’s designated trails.

While we work toward the “No toxic pesticides in our parks” goal, we try to attend these meetings and believe that we have been able to work with SF Environment over the years to get some improvements.

  • SFRPD improved the signage for pesticide use, and is now encoding the use of colored dye to show where actual spraying has taken place.
  • More practical restrictions on pesticide use.
  • We’re encouraged by SF RPD’s reducing herbicide use in the last three years – excluding the Natural Areas (now the Natural Resources Division) and Harding Golf course, which is managed under contract by the PGA Tour. (The graphs below show pesticide usage by SFRPD ex NAP and Harding, and NAP/ NRD’s pesticide use. Please note that all measurements are in fluid ounces of active ingredient, but the scale on the two graphs are different.)

Pesticide Use in San Francisco Natural Areas Creeping Up Again – Oct 2017

We’ve received the pesticide usage reports for the first ten months of 2017, and we’re concerned. After reducing herbicide usage in the last four years, it’s creeping up again in the natural areas. The Natural Areas (now called the Natural Resources Department) has already used more herbicides (measured by active ingredient) than in all of 2016. It hasn’t reached 2015 levels, but park users hoped for further reduction, not an expansion in herbicide use.

San Francisco’s Department of the Environment runs the Integrated Pest Management (IPM) program for city-owned properties in San Francisco. It publishes an annual list of permissible pesticides, and classifies them into Tier III (Least Hazardous), Tier II (More Hazardous) and Tier I (Most Hazardous.)

The unnaturally-named Natural Resources division (NRD) of the San Francisco Recreation and Parks Department (SFRPD) used more Tier I  herbicides than the rest of SFRPD put together (excluding Harding Golf course, which is managed under a separate PGA contract – but including all the other city-owned golf courses). In fact, in the first ten months of 2017,  NRD used 69% of the Roundup and 100% of the Garlon used by SFRPD.

The parks mainly targeted thus far were:

  • Twin Peaks (sprayed 32 times);
  • Glen Canyon (sprayed 27 times);
  • McLaren Park (25 times);
  • Bayview Hill (14 times); and
  • Laguna Honda (PUC property – 13 times).

Other parks that got sprayed over five times in ten months were Mt Davidson (8 times); Marietta (a PUC property – 8 times); and Lake Merced, also 8 times.

NRD INCREASES USE OF CANCER-CAUSING ROUNDUP 

We especially noted that its usage of glyphosate (Roundup/ Aquamaster) has nearly doubled from 2016 (i.e., in ten months, NRD used nearly twice as much glyphosate as in the whole of 2016).

This is particularly worrisome since Roundup probably causes cancer. We wrote about that in these articles: World Health Organization: Roundup “Probably Carcinogenic” and in this report from an EPA scientist before she died reported on problems with pesticide assessments: “It is Essentially Certain that Glyphosate Causes Cancer”

This is the first time since the report came out we’ve seen an increase in its use.

GARLON IS WORSE

The other major Tier I pesticide being used is Garlon 4 Ultra (triclopyr). NRD is the only section of SFRPD that uses this chemical, which has been considered Most Hazardous and HIGH PRIORITY TO FIND ALTERNATIVE at least since 2009. It’s twenty times as harmful to women as to men. (Here’s our quick presentation on the subject: Garlon v. Oxalis in Ten Easy Slides.)

NRD uses this on oxalis, an early spring-flowering plant beloved of children, pollinators, and wildlife – and the general public, who enjoy its bright blooms as a sign of spring. It’s the only use of Garlon by NRD, and if they abandoned the vendetta against these Bermuda buttercups, they would not need to use this awful pesticide.

NEW WAR TARGETING CAPE MARIGOLD

Meanwhile, there’s a new city-wide war on a naturalized species: against arctotheca, or Cape Marigold. It’s another yellow-flowering plant that grows all over our city’s parks, and it’s on the list of 40 species (and counting) that the NRD wants to poison.  Here’s a picture from McLaren Park (together with Great Blue Heron that’s probably hunting gophers).

Cape Marigold occurs in both a fertile and an infertile form; both are considered only Moderately invasive by the California Invasive Plant Council – as is oxalis.

Unless NRD changes its approach and objectives to naturalized species of plants – and recognizes the need for inclusiveness in natural areas – there is little likelihood of eliminating pesticides from our parks. Aggressive management will inexorably result in increased herbicide use.

WHAT ABOUT THE REST OF SFRPD?

By contrast, the rest of SFRPD (excluding Harding Golf Course) seems to be on track to reduce usage again from 2016. For which kudos!

[Edited to Add: The graph below was corrected to indicate the last column shows usage only through Oct 2017, not the full year.]


The only department besides Natural Resources to regularly use pesticides is the Golden Gate Nursery. They wish to make sure the nursery stock they supply is pest-free before propagating it. This is less of a concern than NRD for several reasons: It’s not a public space, usage is confined in a small area and not on parks and hillsides where chemicals could spread to other areas.

We are concerned, though, that they are experimenting with several herbicides that were not earlier on SF Environment’s list: Axxe, Suppress, Clearcast and Finale. They are all considered Tier II, according to Dr Chris Geiger of SF Environment’s IPM.

Of these Axxe and Suppress seem to be less harmful. Suppress is considered acceptable for organic farming.

Clearcast is more concerning, as is Finale. You can see the Clearcast Label here: clearcast_Label.pdf 2016

Here’s the Finale Label: finale_msds

Both these pesticides have cautions regarding potential harm from immediate exposure. We will further research them, but more than the specifics, we’re concerned at the direction. Rather than working to eliminate herbicides from our parks, SFRPD seems to be looking for substitutes for Roundup. Thus far, these two chemicals have been used only in Nursery areas – the GGP Nursery, and the nursery at the Botanic Gardens.

SFRPD now has five Integrated Pest Management Specialists (compared to one before). This is good news to the extent that they will be working on mosquito abatement and alternatives to rat poisons. It’s bad news if it encourages SFRPD to open new battle fronts (like the war on Cape Marigold), or increase use of herbicides in the water, rather than changing its approach to eliminate pesticides in our parks. Here’s the note about their activities from an October meeting of SF Environment’s Policy Committee:  102317_attachment_c_-_agency_ipm_updates_for_2017

SF Forest Alliance reiterates our commitment to working toward No Toxic Pesticides in our parks. We recognize that it will be an uphill battle, as all current interests are in continuing pesticide use. Nevertheless, we believe that it is possible and is a worthwhile and environmentally-friendly goal for San Francisco.

 

 

Pesticides in our Parks – Bernal Hill

The Natural Areas program (now called the Natural Resources Department) regularly uses herbicides in many of our parks. We’ve published pictures before of Glen Canyon and Mt Davidson.

This time, it’s Bernal Hill.

This hill apparently needs herbicides.

So they’re putting Polaris – that’s imazapyr – on the blackberry and cotoneaster.

It takes a five-person team.

[Edited to Add this section about the famous Bernal Hill Blackberry Patch.]

THE FAMOUS BERNAL HILL BLACKBERRY PATCH

Hope they don’t take out the famous Bernal blackberry patch that’s brought so much joy to families.

It’s a thing, and has been for years. Here’s a 2008 article called Bernal Hill Blackberry Bonanza.  And here’s a quote from a 2009 article in the SF Chronicle, indentifying hidden treasures in San Francisco: ‘Bernal Hill Blackberry Patch. “The locals might hate us for sharing this, but there is a huge wild blackberry patch on the north side of Bernal Hill where we forage pounds and pounds of berries every summer for jam-making. So delicious.”‘ And the Bernalwood blog hailed the start of the blackberry season in 2012 in It’s Official: Blackberry Season Under Way in Bernal Heights

SFRPD – people love blackberries, and Bernal has the best crop in the city!

San Francisco Forest Alliance stands for no pesticides in our parks. We also hope that SFRPD will respect public resources that people love.

Pesticides on Blackberry in Fruiting Season

Recently, one of our neighbors was walking on Mt Davidson. It’s the time of the year when the blackberry bushes bear fruit, to the delight of children and the public in general (and not a few animals and birds). She was unpleasantly surprised to find that the bushes were to be sprayed with herbicide.

“It’s the fruiting season!” she noted, wondering if this was legal.

Unfortunately, it is.  In 2016, SF Environment imposed restrictions on spraying blackberry bushes during the fruiting season. But the way the restrictions are written, they apply only to Tier I (“Most Hazardous”) pesticides and not to the Tier II (“More hazardous”) pesticides that the Natural Resources Division (NRD – formerly Natural Areas Program) also uses quite frequently. The NRD commonly uses “the fearsome four” pesticides: Garlon, Roundup, Milestone VM and Polaris (also called Habitat). All of them are toxic in some degree.

The herbicides used in this case are Milestone VM (aminopyralid) and Polaris (Imazapyr). Both are toxic and are classified as “More Hazardous” (Tier II). Imazapyr can damage eyes, and its breakdown product is a neurotoxin, which means it causes nerve damage. Aminopyralid is a newer chemical, but is known to be astonishingly persistent. It’s banned in some places because of that.

 

SF ENVIRONMENT’S PESTICIDE USE RESTRICTIONS

In 2016, the SF Department of the Environment engaged in a lengthy process of trying to improve its restrictions on  some of the most problematic use of pesticides in our parks.

(You can read the entire compliance guidelines here as a PDF. It’s from the SF Environment website. sfe_th_ipm_compliance_checklist – Copy )

Among them, they developed these restrictions:

 Pesticide use

✓ A written recommendation from a licensed Agricultural Pest Control Advisor (PCA) is required for any pesticide use. Departments that do not have PCAs on staff should contact the SF Environment IPM Manager.

✓ Only pesticides on the current SF Reduced Risk Pesticide List may be used. Usage must fall within the “limitations” listed for each product, along with label requirements.

✓ ‘Most hazardous’ (Tier I) herbicides have special limitations:

  • Use is prohibited for purely cosmetic purposes.
  • Use is prohibited within 15 feet of designated paths. If a park map exists, designated paths are those found on the maps. Otherwise, designated paths are those actively maintained by staff.
  • Use is prohibited within 15 feet of schools, preschools, playgrounds, or other areas frequented by children.
  • Use on blackberry bushes is prohibited when fruit are present 
  • If within the City limits, use requires onsite supervision by a licensed person (PCA, QAL/QAC) o No broadcast spraying with a boom is permitted except for golf courses (targeted spraying only)
  • Certain pesticide use is restricted in designated Red-Legged Frog habitat, which includes Golden Gate Park, Lake Merced, and several other areas in San Mateo and Alameda County.

Notification

Posting for pesticide use must be done 3 days before treatment, and remain up for 4 days after treatment, except for least-hazardous (Tier III) products, which require posting only on the day of treatment.

✓ Postings must clearly identify the area to be treated. Signs should be placed at locations most likely to be seen by members of the public using the treated area.

✓ Posting is not required for median strips or rights-of-way when these areas are not intended for public use.

✓ Posting is not required for areas inaccessible to the public. [See our recent article on this: San Francisco Pesticides and Inaccessible Areas]

✓ ‘Most hazardous’ (Tier I) herbicides have special notification requirements:

  • Blue dye must be used, and this must be noted on the posting sign. Blue dye is not required in areas where 1) posting is not required, and 2) staining may occur, such as ornamental stone median strips.
  • When treatment sites that cannot be readily identified by the posting sign alone, a map showing the general location of expected treatment area(s) must be attached to the posting sign.

MORE ACTION REQUIRED

Though the added restrictions in 2016 were a step forward, much more is needed. NRD seems willing to go by the letter of the rules, not the spirit of it. Blackberry should not be treated with persistent herbicides at all, especially not in the fruiting season. It’s going to affect children, wildlife, and anyone who loves picking the berries in season… most parkgoers.

San Francisco Forest Alliance stands for Pesticide-Free Parks – including natural areas.

San Francisco Pesticides and “Inaccessible Areas”

One of our supporters has been pursuing a concerning issue regarding pesticide application in San Francisco. As our regular readers will know, proper notices are required when spraying toxic herbicides (designated Tier II, More Hazardous and Tier I, Most Hazardous) on city property – including our parks. Recently, SF Environment made changes to its application guidelines to provide better protection to the public, and to workers applying the pesticides. This requirement includes adding a blue dye to the mix so the public can see what has been sprayed with these chemicals.

However, there’s a loophole. Neither notices nor dye are required if the area is “inaccessible to the public.”  As the Natural Resources Department (renamed from NAP, the Natural Areas Program) works to limit public access to only a few “maintained trails” we’re concerned that this will give SF Recreation and Parks a free pass to use toxic herbicides like glyphosate (Roundup) without notices or dye.

So concerned citizen Tom Borden gathered information under the Sunshine Act. His research culminated in this letter to the Commissioners for the Environment.

Commissioners,

The department you oversee is willfully violating San Francisco’s Environment Code by offering City departments a loophole to avoid posting when pesticides are sprayed.  The Environment code Section 304 requires posting for all pesticide applications in all locations.  (One exception is noted, “right-of-way locations that the general public does not use for recreational purposes”.  This is intended to allow unposted treatments at places like roadway median strips, but certainly not in parks, adjacent to sidewalks and in watersheds.)

However, the IPM Compliance checklist says something very different, “Posting is not required for areas inaccessible to the public.”  This “publicly inaccessible” exception violates the Code and puts City workers and the public at risk.  According to IPM staff, they leave it up to individual departments to decide which areas are “publicly inaccessible”.  IPM staff have stated they do not make it their business to monitor these designations.

This clearly puts City employees at risk of unwitting exposure to pesticides.  It also puts the public at risk as land managers are left to their own devices to decide which areas qualify as “publicly inaccessible”.

On top of this, the Reduced Risk Pesticide List: Restrictions on “most hazardous”(Tier I) herbicides, was revised this March to remove the requirement that blue dye be added to Tier I herbicides if they are used in places where posting is not required.  In other words, if the land manager deems a location to be “publicly inaccessible”, there is no requirement to post and no requirement to use the indicator dye.  Anyone who goes through the area, City employee or member of the general public, will have no idea they are exposing themselves to Tier I herbicides.  (Why would you remove this cheap protection, even if it did only benefit the person applying the herbicide?  Also, the blue dye enables them to see where they sprayed, allowing them to apply the herbicide more efficiently.)

This posting loophole is not necessary under the precautionary principle and it violates the law.  It opens the City to lawsuits from employees who were not provided the protections the law promises.  I hope you will have the Department to rectify this.

See the email exchange below for additional information..

Thank you for your attention to this matter.

Tom Borden

EMAILS IN THE BACKSTORY

If you want to see the email trail yourself, here it is:

This is a Sunshine request.

San Francisco Environment Code Section 304.(e) allows the Department of Environment to grant permanent (ongoing as opposed to one time) exemptions to the notification requirements of the code.

(e)   The Department may grant exemptions to the notification requirements for one-time pesticide uses and may authorize “permanent” changes in the way City departments notify the public about pesticide use in specific circumstances, upon a “finding” that good cause exists to allow an exemption to the notification requirements. Prior to granting an exemption pursuant to this subsection, the City department requesting the exemption shall identify the specific situations in which it is not possible to comply with the notification requirements and propose alternative notification procedures. The Department shall review and approve the alternative notification procedures.

Please provide a list of all “permanent” exemptions that have been granted in the last 10 years.  If any have been granted to the Recreation and Parks Department or the SFPUC, please provide copies of those “findings” and a copy of the exemption request from the department.

He got a response – a phone call with Chris Geiger, responsible for San Francisco’s Integrated Pest Management program. Chris performs a delicate balancing act between reducing pesticide use and dealing with land managers who want to use these chemical weapons against “invasive” plants.  Tom asked for confirmation of the discussion in writing. He got it from Anthony Valdez, Commission Secretary.

On 7/5/2017 3:14 PM, Valdez, Anthony (ENV) wrote:

Tom:
As Chris Geiger discussed with you – the Department of the Environment has not granted any permanent exemptions to the posting requirements of Environment Code Section 304(a) for publicly accessible parcels. We do allow variances from the posting requirements for some publicly inaccessible parcels, most notably certain areas of San Francisco International Airport and closed utility rights-of-way managed by the Public Utilities Commission.
Thanks, Anthony
Anthony E. Valdez, MPA
Commission Secretary

Okay, good. So just to make sure, Tom asked:

Anthony,

Are any areas managed by the Recreation and Parks Department considered “publicly inaccessible parcels”?
If so, please provide a list of those areas and the associated variances from the posting requirements.

Thanks, Tom

Anthony responded:

On 7/12/2017 2:48 PM, Valdez, Anthony (ENV) wrote:
Tom –
Apologies for my delay in coordinating a response – we have two Commission on the Environment meetings this week. Please see the response below from Chris Geiger. Again, I encourage you to feel free to email or call Chris with any questions you may have:

The Department of the Environment does not review individual parcels to determine if they qualify as “publicly inaccessible.” That determination is left to the individual departments, including the Dept. of Recreation and Parks. We therefore do not have any specific variances or exemptions on file.  The reference document for this policy is the IPM Compliance Checklist.

You mentioned on the phone that you want to ascertain whether park areas adjacent to trails might be considered “publicly inaccessible” if there were signage requiring users to stay on the trail.  The answer is no. The posting exemption for publicly inaccessible areas is meant to apply to work areas, such as the Rec & Park Corporation Yard, not to public parks. We have never and would not ever grant any posting exemption for this kind of situation, and in my tenure we have never had any discussions or written exchanges with the Dept. of Recreation & Parks where this question has even come up. In my experience, Recreation & Parks has been quite careful and responsible in complying with posting requirements.

Anthony E. Valdez, MPA
Commission Secretary

That sounded encouraging. Just to confirm, though…

Thanks Anthony and Chris,

It’s good to know all herbicide applications in regular parkland and Natural Areas will be posted and that blue marking dye will be used.

On a related topic, Aquamaster was sprayed on Mt Davidson on July 5 [2017].  The treatment was to control poison oak growing onto a primary trail.  The herbicide was sprayed on PO and grass that was literally on the trail edge.  The trail was not closed off as required.  Attached are photos of the sign and the application area. More training and better supervision needed?

Tom

.

 

He followed up with another email.

Chris and Anthony,

In your July 12 email to me you say:

“The Department of the Environment does not review individual parcels to determine if they qualify as “publicly inaccessible.” That determination is left to the individual departments, including the Dept. of Recreation and Parks. We therefore do not have any specific variances or exemptions on file.  The reference document for this policy is the IPM Compliance Checklist.”

I see the Compliance Checklist does say, “Posting is not required for areas inaccessible to the public.”  However, the actual law,  SF Environment Code Chapter 3, does not make any such exception.  The posting exception in the Checklist violates the language of the Environment Code.  How does the Department of Environment justify making this exception?

Chapter 3 is meant to protect everyone in the City.  The IPM Compliance Checklist note removes this protection for City employees.  Doesn’t this leave the City open to lawsuits by willfully removing protections the law promises City employees?

As you know, I am concerned the RPD will use this as a loophole to avoid posting requirements in Natural Areas since their position is that the public is prohibited from straying off trail into those areas.  You state above that your department will not provide oversight of the “publicly inaccessible” designations made by City land managers.  This leaves in doubt what really qualifies as publicly inaccessible and as a result, leaves the public open to exposure to herbicide applications that are not posted or marked with blue dye.

I appreciate that your email also makes assurances that you have not granted RPD any additional posting exceptions, beyond this one granted to all City departments.

Looking forward to your reply,

Tom Borden
415 252 5902

After that, there was the letter to the Commissioners to express the same concerns.

Thanks, Tom, for trying to protect everyone from toxic herbicides in our parks!